Ferdinand Decaprio and Claire Decaprio - Page 6

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               1986, he received unreported cash income from the two                  
               businesses that he owned and that these cash receipts                  
               were unreported in the corporate books.                                
                         (d)  On that same date, petitioner Ferdinand                 
               DeCaprio allocuted, under penalty of perjury or false                  
               statement, that the additional unreported income that                  
               he received was as follows:  $66,000 during the taxable                
               year 1983; $16,798 during the taxable year 1984;                       
               $19,835 during the taxable year 1985; * * *                            
                         (e)  On that same date, petitioner Ferdinand                 
               DeCaprio allocuted, under penalty of perjury or false                  
               statement, that he used the unreported cash income to                  
               pay for his personal expenses.                                         
                         (f)  On that same date, petitioner Ferdinand                 
               DeCaprio allocuted, under penalty of perjury or false                  
               statement, that he knew it was illegal to not report on                
               his income tax return the additional cash income listed                
               in subparagraph (d) above.                                             
                         (g)  On that same date, petitioner Ferdinand                 
               DeCaprio allocuted, under penalty of perjury or false                  
               statement, that the medication he was using at that                    
               time did not affect his ability to think.                              
                         (h)  [P]etitioner Ferdinand DeCaprio's fraud-                
               ulent omission of specific items of income on his                      
               income tax returns filed for the taxable years 1983,                   
               1984, 1985 * * *, is a part of a * * * pattern of                      
               intent to evade taxes.                                                 
                         (i)  Petitioner Ferdinand DeCaprio under-                    
               stated his taxable income on his income tax returns for                
               the taxable years 1983, 1984, 1985 * * *, in the                       
               amounts of $66,000, $16,798, $19,835, * * *, respec-                   
               tively.                                                                
                         (j) Petitioner Ferdinand DeCaprio under-                     
               stated his income tax liabilities on his income tax                    
               returns for the taxable years 1983, 1984, 1985 * * *,                  
               in the amounts of $22,380, $7,474, $9,587, * * *,                      
               respectively.                                                          
                         (k)  Petitioner Ferdinand DeCaprio fraudu-                   
               lently, and with intent to evade tax, omitted from his                 
               income tax returns for the taxable years 1983, 1984,                   
               1985 * * * income in the amounts of $66,000, $16,798,                  
               $19,835, * * *, respectively.                                          



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